Thad Delaughter v. Ronald Woodall
909 F.3d 130
| 5th Cir. | 2018Background
- Thad Delaughter, a Mississippi prisoner with rheumatoid arthritis and prior hip replacement, alleged he needed hip replacement and reconstructive surgery that was delayed or denied during incarceration.
- He sued Michael Hatten (medical administrator at SMCI) and Dr. Ronald Woodall (Wexford physician) under 42 U.S.C. § 1983 claiming Eighth Amendment deliberate indifference; sought injunctive relief (surgery) and damages.
- Dr. Woodall treated Delaughter with medication and steroid injections, asserted he could request but not authorize/schedule off-site surgery; he submitted an unrebutted affidavit that he lacked authority to arrange surgery.
- Delaughter saw orthopedist Dr. Nipper, who recommended surgery in 2011; surgery was later cancelled. Records and testimony left disputed reasons for cancellation (physician cancellation, UMMC refusal, or MDOC refusal to pay).
- District court granted summary judgment to both defendants and denied Delaughter’s motions for counsel; on appeal the Fifth Circuit affirmed summary judgment for Dr. Woodall, reversed and remanded claims against Hatten (official and individual capacities), vacated denial of counsel, and remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Dr. Woodall was deliberately indifferent by not obtaining surgery | Woodall knew surgery was required and failed to obtain it | Woodall can only request referrals and lacked authority to authorize/schedule/pay for surgery | Affirmed for Woodall: no genuine fact issue; unrebutted affidavit shows lack of authority so no personal involvement in denial of surgery |
| Whether Hatten (official capacity) is immune to injunctive relief under Eleventh Amendment | Ex parte Young exception permits prospective injunctive relief to obtain surgery | Sovereign immunity bars official-capacity injunctive claims | Reversed and remanded: district court failed to apply Ex parte Young; complaint alleges ongoing Eighth Amendment violation seeking prospective relief |
| Whether Hatten (individual capacity) entitled to qualified immunity for delay/denial of surgery | Hatten unjustifiably delayed surgery; clearly established law forbids unjustified delays in necessary surgery | Delay resulted from medical decisions (surgeon cancelation, UMMC refusal) or other non-actionable factors; thus no constitutional violation | Reversed and remanded: genuine factual disputes about reasons for delay and Hatten’s authority preclude summary judgment; clearly established law could put Hatten on notice |
| Whether district court abused discretion denying appointment of counsel | Case complexity, factual twists, and difficulty for pro se prisoner justify counsel | No exceptional circumstances; plaintiff competent to proceed pro se | Vacated denial and remanded: court should reconsider appointment of pro bono counsel given case complexity and factual issues |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (1976) (Eighth Amendment prohibits deliberate indifference to serious medical needs)
- Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference requires knowledge of substantial risk and disregard by failing reasonable measures)
- Wilson v. Seiter, 501 U.S. 294 (1991) (Eighth Amendment deliberate indifference standard principles)
- Ashcroft v. al-Kidd, 563 U.S. 731 (2011) (two-prong qualified immunity framework)
- Mendoza v. Lynaugh, 989 F.2d 191 (5th Cir. 1993) (delay in medical care can violate Eighth Amendment if deliberate indifference results in substantial harm)
- Ex parte Young, 209 U.S. 123 (1908) (states’ sovereign immunity does not bar prospective equitable relief to enjoin ongoing federal-law violations)